Do my responsibilities differ under subaward and vendor relationships? How do I determine what types of requirements to apply to my subrecipients or vendors?

Your relationships do differ under vendor and subrecipient relationships. When you enter into a subrecipient relationship, you are required to flow down to the subrecipient the same or similar requirements to those that ONC includes in your award, such as prior approval requirements and requirements related to program income and property. You, as the recipient, are required to monitor subrecipient compliance with those requirements, and an Office of Management and Budget Circular A-133 audit of your award will look at how you monitored your subrecipients. These types of requirements do not apply in a relationship with a commercial entity, where the contract between you and the vendor governs. However, the selection of a vendor must comply with the requirements of your organization’s procurement process; in which case the A-133 audit would look at whether you complied with those requirements. Grants Management Advisory 2012-03 provides detailed information about the requirements you must apply to your subrecipients and vendors, which, based on the type of subrecipient or vendor organization, may differ from the requirements that apply to you.

Content last reviewed on April 29, 2019
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